taxi & private hire licensing policy consultation...

Taxi & Private Hire Licensing Policy

Consultation responses

Part 1: The policy requirements

Appendix 4

2

Contents

Taxi & Private Hire Licensing Policy Consultation responses .................................... 1

Introduction and background .................................................................................. 3

Q1: Who responded to our consultation? ............................................................... 4

Q2: Layout of the draft policy .................................................................................. 5

Requirements of applicants for a taxi or private hire licence ................................... 7

Q3. Reintroducing a practical driving assessment for taxi & private hire drivers ... 7

Q4. Criminal record checks ................................................................................. 11

Q5. Overseas criminal history checks .................................................................. 14

Q5b ....................................................................................................................... 17

Q6. English language requirement ...................................................................... 19

Q7. Code of Conduct for drivers .......................................................................... 21

Q7b ....................................................................................................................... 23

Q8. Executive vehicle status ................................................................................ 25

Question 8b .......................................................................................................... 27

Q9. CCTV in taxi and private hire vehicles .......................................................... 29

Q9b ....................................................................................................................... 32

Q10: Other comments ......................................................................................... 34

End of Part 1 ......................................................................................................... 36

Appendix 4

3

Introduction and background

Elmbridge Borough Council regulates taxi and private hire services within the

Borough. Whilst there was no legal requirement for us to adopt a taxi and private hire

licensing policy, a policy is an integral part of the licensing process. It allows us to

inform and guide stakeholders and helps to provide consistency in decision making.

These policies must be reviewed as necessary to ensure they remain current.

In 2014, the Law Commission published recommendations for reforming the law

relating to taxis and private hire services. In 2018 a Government led Independent

Task and Finish Group on Taxi and Private Hire Vehicle Licensing set out a road

map to reform the taxi and private hire sector with emphasis on safeguarding and

public safety. In February 2019 the Government published a response to that report,

immediately followed by a consultation on draft statutory guidance to licensing

authorities incorporating several recommendations for safeguarding and public

safety.

We subsequently reviewed and revised our existing policy to strengthen measures to

uphold public safety, safeguard children and vulnerable adults and to improve air

quality by referring low emission taxi and private hire vehicles.

On 24 June 2019, the Council’s Licensing Committee considered the reviewed taxi

and private hire licensing policy and the proposed revisions to it. The Committee

agreed that officers should consult on the reviewed policy, on proposals for

achieving a fleet of low emission taxi and private hire vehicles, and whether it was

necessary for the Council to require mandatory use of CCTV in licensing vehicles.

The Committee agreed that a public consultation for a period of 12 weeks would be

held to enable full engagement with key stakeholders.

The consultation ran from 15 July 2019 until 7 October 2019 and included email and

online consultation, face to face interviews and focus groups involving members of

the taxi and private hire trade. Meetings were arranged to accommodate

stakeholders working commitments.

We asked questions on the key proposed changes to the Policy to understand

whether the respondent agreed with the change (yes, no or don’t know) and why.

Part 1 of the report sets out the questions and responses we received to the

consultation on the policy. Part 2 sets out the responses we received to the

consultation on reducing taxi emissions which ran concurrently.

Appendix 4

4

Q1: Who responded to our consultation?

We received 58 responses to the online consultation, one emailed response and one

response from the private hire operator’s workgroup.

Respondent Total %

Business/organisation not affiliated with the taxi/private hire trade 1 2%

Taxi or private hire vehicle owner 2 3%

A private hire operator 4 7%

A regular taxi or private hire user 7 12%

A taxi or private hire driver 44 76%

A member of the public not affiliated with the taxi or private hire

trade or infrequent taxi or private hire users

0 0%

Representative of an organisation affiliated with the taxi or private

hire trade

0 0%

Appendix 4

5

Q2: Layout of the draft policy

Consultation question 2: “We have changed the layout of the draft Policy to make it

easier to read and understand”. We asked respondents if they agreed with this

change and to say why.

Yes No Don’t know

13 35 10

22% 60% 17%

Appendix 4

6

Responses to question 2

(1) Nine respondents who answered “yes” to question 2, did not give

reasons for their answer. The remaining four responded as follows

1. Because it’s the way to go

2. For road and passenger safety.

3. gives us (drivers) a better understanding of what’s needed in day to day

driving .... I did it and found it very useful!!

4. I agree with the changes but in the document, there is no mention or

acknowledgement of new technologies that allow non-Elmbridge taxis to

operate in the Elmbridge area. These drivers and vehicles may not comply

with Elmbridge standards.

(2) 22 respondents who answered “no” to question 2, did not give

reasons for their answer. The remaining 13 responded as follows:

1. Because happy with system now

2. Because I don't like

3. because some drivers have been living and working here for 20+ years and

speak write and understand English very well. Also, I don't think drivers

need to take a retest in the practical unless they have displayed concerning

behaviour in driving.

4. Don’t need any changes. New changes are not business friendly.

5. Everything works well don't need for any change

6. exiting policy is better for now

7. happy with present policy

8. I am with the existing policy.

9. I don’t agree with certain aspects of the draft

10. it is extra expense for drivers who are already suffering, and you should be

relaxing the conditions as tinted windows as they can cost thousands to

replace

11. New changes shouldn't be taken place as current policies are ok but should

be even a bit more flexible.

12. Some policies are wrong

13. We already have extensive checks and costs. WHAT about the driver????

Has anyone ever considered them. How they will afford it. List is endless

(3) All 10 respondents who answered “don’t know” to question 2, did not

give reasons for their answer.

Appendix 4

7

Requirements of applicants for a

taxi or private hire licence

To grant a licence for a taxi or private hire driver, private hire operator or vehicle

proprietor, the Council must be satisfied that the applicant is suitable to hold that

licence. This is called a “fit and proper” person test.

To help us decide if an applicant is a “fit and proper person”, we require that person

to satisfy several requirements before making their application and to provide

evidence that they have done so.

We propose several changes to those requirements and would like to hear your

views.

Q3. Reintroducing a practical driving assessment

for taxi & private hire drivers

Please see paragraphs 2.24 to 2.26 and 12.6 to 12.9 of the draft Policy.

Taxi and private hire drivers are responsible for transporting their passengers safely

and the Council expects them to show a level of driving skill and ability associated

with that of an experienced and safe driver.

The Council previously required drivers to pass a taxi driving assessment but this

was discontinued in 2016 because the Driver and Vehicle Standards Agency who

carried out the assessment, stopped doing so.

We have now identified suitable alternative assessments and propose reintroducing

the requirement that drivers complete a practical driving assessment before we will

grant or renew a licence. The assessment will consider issues specifically related to

taxi and private hire driving, and the focus will be on road safety and the safe

conveyance of passengers.

This requirement would not apply for drivers who have previously completed the

DVSA test and have been continuously licensed with Elmbridge Borough Council

since that time.

Appendix 4

8

Q3. Do you agree with this proposal?

Yes No Don’t know

21 36 1

36% 62% 2%

Question 3 chart

Appendix 4

9


(1) 17 respondents who answered “yes” to question 3, did not give


1. Because it would show that they are capable

2. Cannot work with any criminal offence.

3. yes, it makes us all safer

4. yes, but not for the existing driver. Better if applies for new drivers



1. because if we were not safe drivers we wouldn't have passed our

practical driving test. also, majority of us are safe and careful drivers

and it’s not fair on us to be retested. if there were to be a complaint

against us with evidence to show carelessness than that is acceptable

2. Been driving for so many years so I find it not needed

3. Existing drivers who do not exceed the driving licence points threshold

prove their level of road safety in conveying passengers, if they exceed

the points limit then assessment can be justified.

4. For current taxi or private hire license holders, they should not be

required to do a test.

5. I agree with the driving test. With regards to the council agent deciding,

on their personal opinion, whether an applicant is a suitable, is wholly

inappropriate. It should be based purely on FACTUAL evidence!!

6. I have been driving for 24 years. I’m an experienced driver. It’s the

other road users who drive carelessly.

7. I have been a continuous driver for over18 years I think I've proved my

worthiness

8. I think there should be not at all driving practical exams as all drivers has

got at least 3 years’ experience I don’t think it’s necessary it should only

apply to drivers who has got licence lease then 3yrs

9. I think only who new applicants should have to take the test, and drivers

who have not done a dvsa test, with points on their license.

10. If a person can pass a DVLA test. He should be fine.

11. Not for renewals

12. Only for new drivers or drivers who hold license keys then 5 years

13. Retest of driving isn't fair. I would personally say that such as many of

your current policies are quite friendly similarly new policies should also

be so and even more lenient.

Appendix 4

10

14. Right now, law is good

15. the reason I don't agree is the driver passes a driving test anyway and

more expensive and harder times for drivers

16. This must only be mandatory for new drivers. The council discontinued

this and issued licenses at that time without this test. We were not told

we would have to take this test at a later date, why driver should take

this unnecessary stress without any reason? The drivers who were

issued the licenses without this test are working without any complaint

and should not be punished with the hassle and cost of this test. Does

this mean council has compromised public safety at that time when

licence was issued? I don't think so. If you get driving related

complaints of any driver, council can then ask for a test. Even if drivers

who earlier passed the test, it does not guarantee that they are driving

as required. There are drivers those got DVLA driving licences got

licence cancelled even if they passed the test. The council issued

licenses with this belief that we will drive safely and without any safety

complain. It is not fair to ask a test now.

17. this test is just for driving a car not for taxi quality service waste of time

and money

18. you can start with new drivers not the existing drivers

19. You can’t give someone a license and then move the goalposts!! Test

should be for new applicants.

(3) The respondent who answered “don’t know” to question 3, did not

give reasons for their answer.

Appendix 4

11

Q4. Criminal record checks

Please see paragraphs 2.27 to 2.34, 5.9 and 6.12 of the draft Policy.

We will always consider a person’s criminal record history and other related

information before we grant a licence. We currently require all applicants to obtain

details of their history from the Disclosure and Barring Service (DBS) and to submit

that information to us.

In addition to criminal record information, the DBS disclosure can also provide details

of individuals barred from working in regulated activity with children or vulnerable

adults.

This information is available to us only if we require the applicant to submit to us, an

“enhanced” DBS disclosure with access to the ‘barred’ list.

Currently, the Council only checks this information when an existing licence holder

applies to renew their licence and this could be every three years.

The Council is proposing that all taxi and private hire drivers and private hire

operator’s ‘sign up’ to the DBS update service which will allow the Council to

undertake instant and secure online checking of a licence holder’s criminal record at

any time.


Yes No Don’t know

48 8 2

83% 14% 3%

Appendix 4

12

Question 4 chart

11

32

5

2

4

38

1 1

0

5

10

15

20

25

30

35

40

Don't know No Yes

A business ororganisation not

affiliated with the taxi orprivate hire trade

1

A private hire operator 1 3

A regular taxi or privatehire user

2 5

A taxi or private hiredriver

2 4 38

A taxi or private hirevehicle owner

1 1

Appendix 4

13




1. But it shouldn't look like that one (applicant) is being ripped off by

charged £40.00 again and again. And/or overseas DBS shouldn't be

conducted as abroad's poor process. (3 responses are the same)

2. But it shouldn't look like that one is being ripped off by charged £40.00

again and again. And/or overseas DBS shouldn't be conducted as

abroad's poor process.

3. criminal back ground checks are good

4. For safety.

5. I’m ok so I don’t have a Problem with that.

6. It would mean one less thing for the driver to update regularly

7. •Necessary

(2) Seven respondents who answered “no” to question 4, did not give

reasons for their answer. The remaining responded as follows:

Drivers and Operators - Yes. Staff - No.

(3) One respondent who answered “don’t know” to question 4, did not

give reasons for their answer. The other responded as follows:

1. don’t know enough about this

Appendix 4

14

Q5. Overseas criminal history checks

Please see paragraphs 2.36 to 2.38 of the draft Policy.

The DBS cannot access criminal records held overseas therefore, a DBS certificate

may not provide a complete picture of an individual’s criminal record.

The Council currently requires applicants who have lived outside the UK for at least

one year in the last 10, to provide a Certificate of Good Conduct from the Country in

which the person has lived during that period.

The Council is proposing to strengthen this requirement to cover an applicant or

existing licence holder who has spent more than three continuous months outside

the United Kingdom when over the age of 18. In those circumstances the person will

be required to obtain an overseas criminal record check or ‘Certificate of Good

Character’.


Yes No Don’t know

30 24 4

52% 41% 7%

Appendix 4

15

Question 5 chart

Appendix 4

16



reasons for their answer. The remainder responded as follows:

1. Definitely a good idea

2. Good and passenger’s safety


reasons for their answer. The remaining 11, responded as follows:

1. Because of a poor procedure in abroad and do Not meet the standards

of UK and some other countries like UK.

2. I think if a person spends more than 1 year its ok to ask for certificate of

good character . 3 months I think it’s too much.

3. No because of a poor procedure in abroad and do Not meet the

standards of UK and some other countries like UK.

4. No because of a poor procedure in abroad and do Not meet the

standards of UK.

5. No because we are living here long enough time

6. overseas certificate not guaranteed

7. Personally, this should be done when the person obtains his or her

passport/visa to enter the country. All relevant checks should be done

then.

8. their probably 450 drivers in this borough which are good drivers which

are going find it difficult how to get a good conduct certificate as some

countries may not provide this

9. There could be times when you are on holiday or visiting family and

staying in another country for three months or more. It becomes quite

difficult obtaining a criminal record check from overseas country.

10. These checks in some other countries are not transparent. So, it’s a

hassle for drivers and waste of time.

(3) Three respondents who answered “don’t know” to question 5, did not

give reasons for their answer. The other responded as follows

2. again, I don’t have enough knowledge of this

Appendix 4

17

Q5b

In addition, the Council proposes that existing licence holders must inform the

Council in advance, if they intend to spend more than 3 months outside the UK and

that they return their licence and identification badge to the Council for that period to

eliminate the risk of that licence being misused.

Yes No Don’t know

23 30 5

40% 52% 8%

Question 5b chart

Appendix 4

18

Question 5b responses

(1) 21 respondents who answered “yes” to question 5b, did not give

reasons for their answer. The remaining two, responded as follows

1. That’s a good idea.

2. Yes, I agree but upon returning to the UK, a test for license is not required

again to obtain the license unless the license has expired.

(2) 18 respondents who answered “no” to question 5b, did not give


1. Because it's bit too harsh.

2. Because it's bit too harsh. I also request that pls also take care of our safety

& security and take action against UBER whose are operating here

unlawfully.

3. can’t stop people for traveling

4. If one travels abroad in an emergency and are not sure how long they are

going away for. What does one do then. That person should my give his or

her license out to someone anyway

5. Informing the council may be fine but returning the license is not OK

because risk of misuse is same even if driver is in the country.

6. Infringement of rights.

7. license holder takes the job very seriously if we don’t work we can’t eat,

and could you further explain how it would be miss used as the plate

would have to match the registration of the car and the drivers batch has his

picture on it

8. Not necessary

9. people should not have to invade their own privacy by informing the state of

potential future movements or activities

10. We don’t need to do so

(3) Four respondents who answered “don’t know” to question 5b, did not

give reasons for their answer. The other responded as follows:

1. Up to you

Appendix 4

19

Q6. English language requirement

Please see paragraphs 2.58 to 2.59 and 12.10 of the draft Policy.

Taxi and private hire drivers, and private hire operators need to be able to

communicate with their customers to discuss a route or fare, as well as to read and

understand important regulatory and safety information. It is also important that all

licence holders can read and understand information provided to them by the

Council such as the conditions under which they are licensed. It is therefore

essential for public safety that all taxi and private hire licence holders can

communicate in English at an appropriate level.

The Council proposes to introduce a requirement, that all applicants and existing

licence holders must be able to demonstrate that they have adequate English

language skills in reading, writing, speaking, and listening. Do you agree?

Yes No Don’t know

31 22 5

53% 38% 9%

Appendix 4

20

Response to question 6



1. Agree with EBC on this. It should be compulsory.

2. But again, it shouldn't be too harsh as one has to communicate just for a

short while, so the basic level of test will do and should do.

3. Definitely a good idea.

4. The person who have GCSE level should be exempted

5. yes , especially older people who are hard of hearing



1. A driver who can take a knowledge test means he or she knows enough

English

2. for new drivers only

3. I don't think that we don't need to do again and again already uk ba doing

this who is entering UK .without English we can't enter the uk now. Already

existing ones, I don't think need this test

4. I think this should apply only for new drivers.

5. If the driver passes the knowledge test, then I don’t think they don’t have to

do English test

6. More than able to communicate

7. new drivers only not for the existing drivers we are good enough to

communicate with passengers

8. Only necessary if the person in question can’t speak English Before any

license is issued for any reason. This can be done when you see the

person and have a conversation with them

(3) All five respondents who answered “don’t know” to question 6, gave

reasons for their answer as follows:

1. as the knowledge test should be an English test as you have to give

directions to place and it's another expense

2. But again, it shouldn't be too harsh as one has to communicate just for a

short while, so the basic level of test will do and should do.

Appendix 4

21

3. Depends on what onerous way this has to be proved and there is no need

for existing licence holders to prove this as they wouldn't still be in the job if

they could not communicate with passengers.

4. There must be certain exemptions. Like if someone did entry 3 UK

course(Equivalent to B1 European standard) English language course. Or if

they did some course up to NVQ level 2 or interpreter courses of any kind,

he must be exempted. It must not be enforced blindly for everyone if their

education already proves English proficiency.

5. Up to you

Q7. Code of Conduct for drivers

Please see Appendix 2 of the draft Policy.

The Council currently issues driver’s licences with standard conditions. There is a

proposal to replace these conditions with a Code of Conduct for taxi and private hire

drivers. Do you agree with this proposal?

Yes No Don’t know

24 26 8

41% 45% 14%

12 1 13 4

6

2117

1 10

5

10

15

20

25

Don't know No Yes

A business ororganisation not affiliated

with the taxi or privatehire trade

1

A private hire operator 2 1 1


3 4


6 21 17


1 1

Appendix 4

22



reasons for their answer. The remaining respondent answered as

follows

1. Should be Mandatory.


reasons for their response. Eight respondents gave reasons for their

answer as follows:

1. Again, I would say that policies should be business friendly. Not as UBER

are operating with tainted windows &they're more than double even triple in

numbers than us. (2 responses are the same)

2. don't make since

3. existing policy is fine

4. I think having standards conditions has worked very well and may be for the

last 50 years as we work

5. Let the drivers to their job and Spend precious time on spot checks and

illegal vehicles

6. The existing policy is good enough.

7. Why are there more restrictions been I placed for drivers

(3) Six respondent who answered “don’t know” to question 7, did not give

reasons for their response. The other two respondents gave reasons

for their answer as follows:

1. Again, I would say that policies should be business friendly. Thanks

2. Again, I would say that policies should be business friendly. Not as UBER

are operating with tainted windows &they're more than double even triple in

numbers than us.

Appendix 4

23

Q7b

Do you have any views on the requirements?

Yes No Don’t know

12 37 9

21% 37% 15%

Question 7b chart

11 12

1

5

1

6

29

9

1 1

0

5

10

15

20

25

30

35

Don't know No Yes



1

A private hire operator 1 1 2


1 5 1


6 29 9


1 1

Appendix 4

24


(1) Two respondents who answered “yes” to question 2, did not give

reasons for their answer. The remaining 10 responded as follows

1. Any refusal/acceptance of an application should be based purely on fact

and not personal opinion.

2. As above START ENFORCING

3. Courteous and helpful at all times

4. No armband issued- ever.

5. not happy with the potential changes

6. Requirements aren't too bad but again policy makers are supposed to avoid

harshness and strictness.

7. views if you never done job as a taxis driver you will never understood job

8. yes, tint wanted rule should be relaxed as poor drivers are having to change

theirs windows at high cost and the council should give grants to help

drivers


reasons for their answer. The remaining two responded as follows:

1. all good.

2. No comments

(3) Seven respondents who answered “don’t know” to question 7b, did

not give reasons for their answer. The other two responded as

follows:

1. At the moment too, many requirements and not enough business.

2. Requirements aren't too bad but again policy makers are supposed to avoid

harshness and strictness & also should think about our security as Reading

Council banned UBER

Appendix 4

25

Q8. Executive vehicle status

Please see paragraphs 7.21 to 7.32 of the draft Policy.

Licensed private hire vehicles may be used by corporate or business clients, or the

type of clients who for security or personal safety reasons would not want the vehicle

to be identifiable.

For these reasons, the owner or operator of the vehicle may wish to provide an

‘executive’ service more like a private chauffeur driven vehicle.

In such circumstances, the Council may issue a notice that exempts the proprietor of

a licensed private hire vehicle from displaying the Council’s standard plate and for

the driver not to display their driver’s badge.

We will only grant an exemption where specific criteria are met, and we are

proposing changes by providing more detail on the requirements. Do you agree with

this proposal?

Yes No Don’t know

28 18 12

48% 31% 21%

Question 8 chart

Appendix 4

26

Question 8 responses

(1) All 28 respondents who answered “yes” to question 8, did not give

reasons for their answer.



1. Anything or any policy shouldn't be exceptional, and treatment should be

based on equality.

2. Executive status should be stopped. Its used because operators do not like

the taxi plate on their car no other reason.

3. it’s should be easy for them to get executive status as long as they meet all

the conditions as they are going to be delivering a VIP client base

4. Now system is ok

5. The. Current policy is as good as gold. (For gold badge)

6. There are hundreds of uber vehicles that don’t meet Elmbridge

requirements operating in the borough and they have an unfair advantage

7. We should NOT have to disclose prices. This is a financial arrangement

between the Client and operator and has no bearing on the application.

8. Y we wanna show to everybody our id unless someone asked from council

or police officer.

(3) Seven respondents who answered “don’t know” to question 8, did not

give reasons for their answer. The other five responded as follows:

1. Anything or any policy shouldn't be exceptional & treatment should be

based on equality such as UBER drivers work in our council illegally picking

same customers, isn't it exceptional

2. Anything or any policy shouldn't be exceptional, and treatment should be

based on equality.

3. don’t know enough about this

4. N/A.

Appendix 4

27

Question 8b

Do you have any views on the requirements (for executive vehicle status)?

Yes No Don’t know

28 18 12

17% 74% 9%

Question 8b chart

1 1

3

7

5

32

7

2

0

5

10

15

20

25

30

35

Don't know No Yes



1



7


5 32 7


2

Appendix 4

28


(1) One respondent who answered “yes” to question 2, did not give

reasons for their answer. The remaining nine responded as follows

1. A more discreet but permanent badge may be issued

2. I think I've explained about it.

3. I think I've explained that how the same customers are safe while UBER

have tainted windows & we have see through windows & also being

operating here illegally.

4. See above

5. VIP cars should be only high spec cars like Mercedes or similar and should

be granted the badge much easier without providing 3-month worth of VIP

work I have seeing galaxy with VIP badge !!

6. you are already losing a lot of drivers to transport for London which means

licence London work Elmbridge and it effects our business to with much

tougher conditions for us



1. Don’t have one

2. Not really.

(3) The five respondents who answered “don’t know” to question 8b, did

not give reasons for their answer.

Appendix 4

29

Q9. CCTV in taxi and private hire vehicles

Regrettably, despite criminal record checks, a small minority of licensed drivers

nationally have posed a serious risk to passengers including children and other

vulnerable persons. For this reason, the government has suggested that councils

consider making CCTV in licensed vehicles mandatory.

In addition, taxi and private hire drivers themselves could benefit from the installation

of in vehicle CCTV as this can provide a safer environment by:

• deterring and preventing the occurrence of crime;

• reducing the fear of crime;

• assisting the police in investigating incidents of crime;

• assisting insurance companies in investigating motor vehicle accidents

If, following careful consideration by the Council, CCTV in taxis and private hire

vehicles were to become mandatory then the Council would control the data that is

captured, and this would be stored and processed in accordance with data protection

principles.

Q9. Do you agree with that CCTV should be mandatory in taxi and private hire

vehicles?

Yes No Don’t know

10 43 5

17% 74% 9%

Appendix 4

30

Question 9 chart


(1) Eight respondents who answered “yes” to question 9, did not give

reasons for their answer. The remaining two responded as follows

1. Looking in or Looking out

2. More secure for drivers and passengers.



1. as most drivers use their car for private use too and don't want their family

on CCTV

2. Because it will affect the privacy of a taxi/private hire driver. So strictly

shouldn't be enforced.

1 13

75

32

7

2

0

5

10

15

20

25

30

35

Don't know No Yes



1



7


5 32 7


2

Appendix 4

31

3. customers privacy rights

4. I don't think we need. Its cost effective already the business is down. I

consider this also to be an invasion of my privacy

5. I don't want people private images or talk to record.

6. I think it’s not fare on driver’s privacy when he or she is not working the will

be monitor all the time

7. I want to have my privacy

8. Infringement of privacy

9. invasion of privacy

10. it depends on personal privacy as we use our vehicles for personal use too.

agree with the part of being on whilst at work.

11. It’s against the driver private life because the driver uses the taxi for his

family as well

12. It's an invasion of our privacy and I'm worried it might affect our vision and

concentration.

13. its cost effective and its privacy breach

14. its obstructing my driving skills and its extra cost I think we don't need I

have to bear all the time CCTV in mind I can't perform properly

15. My passengers would consider it a gross invasion of their privacy. It's a

significant added cost as well as increased time taken to licence a vehicle.

Potential damage to vehicles CAN electrical system and interior. My

working environment has always been safe and unless that changes, CCTV

is unnecessary.

16. No need

17. not necessary I won't feel comfortable while driving

18. Should not be mandatory.

19. There will be no privacy left for drivers. What if the driver is travelling with

his family or friends.

20. This should be optional

(3) Three respondent who answered “don’t know” to question 9, did not

give reasons for their answer. The other two responded as follows:

1. I'm concerned about this cost and what if someone refuses to be filmed

???? do I refuse them the journey ????

2. mainly the cost, other than that it would be a good idea.

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Q9b

Do you have any other views on the use of CCTV in taxi and private hire vehicles?

Yes No Don’t know

20 35 3

34% 60% 5%

Responses to question 9b

(1) All 20 respondents who answered “yes” to question 9b, gave reasons

for their answer as follows

1. CCTV and Dash cams should be a vehicle owners decision based on actual

demonstrable need.

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2. CCTV should only be used by the driver’s decision. It should only be turned

on when the driver is taking a customer etc.

3. Choose should be given to the drivers if they want or not

4. dash cam should be fine not mandatary

5. Everyone has mobile phones with camera these days. So, any isolated

incident can be filmed by passengers or driver. And there are CCTV.

Cameras in all around Elmbridge area.

6. I have concerns of losing my concentration while driving it effect my driving.

7. In a way you don't allow tinted windows but on the other hand no point to

use CCTV.

8. It will compromise our privacy as well as it will be costly.

9. most customers don't like to be on CCTV too and we drive VIP clients too

and they definitely don't like to be on CCTV

10. Most of the insurers are putting the camera already in the cars

11. see above

12. Should not be mandatory.

13. There are enough controls in place if the operator does their job correctly

14. We cannot be expected to check with every customer at the time of booking

that they agree to CCTV in the vehicle.

15. Who will pay the entire cost of CCTV and storing data? If paid by the

council then I agree with it. What about when vehicle is being used for

private purposes? driver's private life must also be respected. I can't see

anything about these points in proposed policy. It should only be mandatory

if cost is paid by the council and there will be no recordings when vehicle is

used for private purposes.

16. Who’s going to pay for all of this ? It’s ok to come up with all of these

issues but on considers the aftermath. Drivers are currently just serving.

Our rates haven’t increased but nobody has any concerns about that or.

Uber taking our trade. No restrictions on them.

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34

17. Who’s gonna pay for that ? As usual the driver


reasons for their answer. The remaining six, responded as follows:

1. it will breach our privacy

2. It's already fixed in my car by insurance company.

3. No need

4. No need camera in car

5. no views

(3) All three respondents who answered “don’t know” to question 9b, did

not give reasons for their answer.

Q10: Other comments

Do you have any views on other elements of the draft Policy not covered above?

Yes No Don’t know

7 37 14

12% 64% 24%

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35

Question 10 chart


(1) Two respondents who answered “yes” to question 2, did not give

reasons for their answer. The remaining five responded as follows

1. 1. Do not stop issuing vehicle licences for dual licences such as Elmbridge

and PCO. Earning living is getting harder and harder and we need to work

multiple places to pay bills so stopping us having the PCO licence on the

same vehicle would be extremely damaging and expensive for us. 2. Do not

stop issuing 6 passenger plates to Toyota Prius as this will also damage our

trade and will cost us extremely high.

2. Al vehicle renewal should not be affected. Only new vehicles licensed

should come under the councils plan to reduce emissions

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3. EBC always emphasis the safety of passengers (which is good thing).but

what about safety of drivers? Also, EBC has to review their policy about

tinted windows at the moment there are more TFL licensed vehicles and

drivers are being running around in Elmbridge, than Elmbridge licensed

drivers. And 50%of those TFL vehicles have tinted windows. And they

picked up and drop off customers within Elmbridge. Also, EBC should

review their policy about expired badge (when driver unable to renew on

time and has to do whole thing again like a new driver. Which is not only

punishment to the driver it his whole family. Which is. Dry harsh. Every one

of us make mistakes. It shouldn’t be punished like this manner.

4. Yes, but plans must be put in place for ALL taxis working in the Elmbridge

area not just vehicles licensed by Elmbridge. Uber and similar.

5. Yes, please issue the licence of that vehicle who have company fitted tinted

windows because it’s fitted by the manufacturer but if the driver did it by

himself then don’t issue the licence like other councils

(2) Three of the respondents who answered “no” to question commented

as follows:

1. No comments

2. No need

3. self explanatory

(3) 13 respondents who answered “don’t know” to question 14, did not

give reasons for their answer. The remaining respondent commented

as follows:

1. But pls bear in mind that harshness in policy making creates so many

anxieties & bad things in society about which authorities should think

seriously. Thanks

End of Part 1

Appendix 4

taxi & private hire licensing policy consultation...

Documents